Jury Demand in ERICA SANDBERG VS. DIGNITY HEALTH, INC. ET AL| Trellis.Law

On June 02, 2020 a Jury Demand was filed involving a dispute between Sandberg, Erica, and Dignity Community Care Dba Saint Francis Memorial, Dignity Health, Inc., Does 1 To 50 Inclusive, Prieto Md, Victor, St. Francis Memorial Hospital, St. Francis Memorial Hospital Center For Sports, St. Francis Orthopedic Institute, The Estate Of Stephen Van Pelt, The Estate Of Stephen Van Pelt, M.D., Van Pelt Md, Stephen, for MALPRACTICE - MEDICAL/DENTAL in the District Court of San Francisco County.

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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY

MARK J. ZANOBINI, Esq. / RENATA L. BOGOMOLNAYA, Esq. SBNs 121184 / 276350
LAW OFFICE OF MARK J. ZANOBINI, PC
591 Redwood Highway, Building 4000
Mill Valley, CA 94941-3039 ELECTRONICALLY
TELEPHONE NO.: 415-392-8400 FAX NO.(Optional): 415-520-5998

E-MAIL ADDRESS (Optional): admin@zanobinilaw.com FILED
Superior Court of California,
ATTORNEY FOR (Name): Plaintiff
County of San Francisco
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO
STREET ADDRESS: 10/13/2020
MAILING ADDRESS: 400 McAllister Street Clerk of the Court
BY: VANESSA WU
CITY AND ZIP CODE: San Francisco, CA 94102 Deputy Clerk
BRANCH NAME:

PLAINTIFF/PETITIONER: ERICA SANDBERG,
DEFENDANT/RESPONDENT: DIGNITY HEALTH, INC. , et al.

CASE MANAGEMENT STATEMENT CASE NUMBER:

(Check one):
X UNLIMITED CASE LIMITED CASE CGC-20-584686
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)

A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 11/4/2020 Time: 10:30 a.m. Dept.: 610 Div.: Room:
Address of court (if different from the address above):

X Notice of Intent to Appear by Telephone, by (name): Renata Bogomolnaya, Esq. / Mark J. Zanobini, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.

1. Party or parties (answer one):
a. X This statement is submitted by party (name): Plaintiff, Erica Sandberg.
b. This statement is submitted jointly by parties (names):

2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. The cross-complaint, if any, was filed on (date):

3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. X The following parties named in the complaint or cross-complaint
(1) have not been served (specify names and explain why not):

(2)
X have been served but have not appeared and have not been dismissed (specify names):
Stephen Van Pelt, MD - Passed away. Other business entitieswill be dismissed.
(3) have had a default entered against them (specify names):

c. The following additional parties may be added (specify names, nature of involvement in case, and the date by which
they may be served):

4. Description of case
a. Type of case in
X complaint cross-complaint (Describe, including causes of action):
Complaint for Damages
-Professional Medical Negligence / Medical Malpractice.

Page 1 of 5
Form Adopted for Mandatory Use
Judicial Council of California
CASE MANAGEMENT STATEMENT Cal. Rules of Court,
rules 3.720-3.730
CM-110 [Rev. July 1, 2011] www.courts.ca.gov

SANDBERG
CM-110
PLAINTIFF/PETITIONER:ERICA SANDBERG, CASE NUMBER:

CGC-20-584686
DEFENDANT/RESPONDENT: DIGNITY HEALTH, INC.; et al

4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Following a fall in ice followed by an ER visit, Ms. Sandberg was told to see her orthpaedist the next day. on April 30, 2019, she presented to
defendant Dr. Van Pelt at St Francis Hospital Center for Sports Medicine, and was also seen by defendatn Dr. Prieto. New films were taken of
her injured right wrist, and she was splinted. Following days of continued pain and swelling, Ms. Sndberg sought another opinion, which concluded
that she needed surgery at the tine of the accident.Additional surgery will be needed to correct the problem. Damages exceed $200,000.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)

5. Jury or nonjury trial
The party or parties request
X a jury trial a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):

6. Trial date
a. The trial has been set for (date):
b. X No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):

c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Trials/Arbitrations: 11/6/2020, 3/1, 3/8, 3/19, 4/19, 9/27, 10/25/2021, & 1/23/2023.
Mediations/Conferences: 11/11, 11/20/2020, 2/2, 2/26, 3/1, 4/9, 9/28, 10/8/2021, & 12/23/2022.

7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. X days (specify number): 5-6 days.
b. hours (short causes) (specify):

8. Trial representation (to be answered for each party)
The party or parties will be represented at trial X by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
9. Preference
This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for information about the processes available through the
court and community programs in this case.
(1) For parties represented by counsel: Counsel X has has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221.

b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under of Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):

CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 2 of 5

SANDBERG
CM-110
PLAINTIFF/PETITIONER:ERICA SANDBERG, CASE NUMBER:

CGC-20-584686
DEFENDANT/RESPONDENT: DIGNITY HEALTH, INC., et al.

10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):

The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):

X Mediation session not yet scheduled

(1) Mediation
X Mediation session scheduled for (date):
Agreed to complete mediation by (date):
Mediation completed on (date):

Settlement conference not yet scheduled
(2) Settlement
Settlement conference scheduled for (date):
conference
Agreed to complete settlement conference by (date):
Settlement conference completed on (date):

Neutral evaluation not yet scheduled
(3) Neutral evaluation Neutral evaluation scheduled for (date):
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):

Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):

Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
arbitration
Agreed to complete private arbitration by (date):
Private arbitration completed on (date):

ADR session not yet scheduled
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):

CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 3 of 5

SANDBERG
CM-110
PLAINTIFF/PETITIONER: ERICA SANDBERG, CASE NUMBER:

CGC-20-584686
DEFENDANT/RESPONDENT: DIGNITY HEALTH, INC., et al.

11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
c. Coverage issues will significantly affect resolution of this case (explain):

12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case, and describe the status.
Bankruptcy Other (specify):
Status:

13. Related cases, consolidation, and coordination
a. There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate will be filed by (name party):

14. Bifurcation
The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):

15. Other motions
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):

16. Discovery
a. The party or parties have completed all discovery.
b. X The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Plaintiff Initial written discovery Oct-Dec 2020;
Plaintiff Depositions of parties & witnesses Jan - Mar 2021;
Plaintiff Follow-up discovery Apr - June 2021;
Plaintiff Discovery & depositions of experts Per Code.

c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):

CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 4 of 5

SANDBERG

Case Info

Judge

Samuel K. Feng Track Judge’s New Case

Case No.

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Document Filed Date

October 13, 2020

Case Filing Date

June 02, 2020

County

Parties

DIGNITY COMMUNITY CARE DBA SAINT FRANCIS MEMORIAL Defendant
DIGNITY HEALTH, INC. Defendant
DOES 1 TO 50 INCLUSIVE Defendant
GOODMAN, JAMES MICHAEL Attorney for the Defendant
PICCHI, JOSEPH S. Attorney for the Defendant
PRIETO MD, VICTOR Defendant
SANDBERG, ERICA Plaintiff
ST. FRANCIS MEMORIAL HOSPITAL Defendant
ST. FRANCIS MEMORIAL HOSPITAL CENTER FOR SPORTS Defendant
ST. FRANCIS ORTHOPEDIC INSTITUTE Defendant
TABARI, CYRUS ALI Attorney for the Defendant
THE ESTATE OF STEPHEN VAN PELT Defendant
THE ESTATE OF STEPHEN VAN PELT, M.D. Defendant
VAN PELT MD, STEPHEN Defendant
ZANOBINI, MARK JOSEPH Attorney for the Plaintiff
Aaron Schultz Attorneys for Defendants
Renata Bogomolnaya Attorneys for Plaintiffs
Jessica Arenas Attorneys for Defendants
Eric Meissner Attorney
Corinna Meissner Attorneys for Defendants
Adam Stoddard Attorneys for Defendants

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Jury Demand: ERICA SANDBERG VS. DIGNITY HEALTH, INC. ET AL

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